Haws v. Pascagoula-Gautier School District

CourtDistrict Court, S.D. Mississippi
DecidedNovember 2, 2022
Docket1:22-cv-00071
StatusUnknown

This text of Haws v. Pascagoula-Gautier School District (Haws v. Pascagoula-Gautier School District) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Haws v. Pascagoula-Gautier School District, (S.D. Miss. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI SOUTHERN DIVISION

DENICE HAWS PLAINTIFF

v. Civil No. 1:22cv71-HSO-RPM

PASCAGOULA-GAUTIER SCHOOL DISTRICT and MELISSA D’ANGELO DEFENDANTS

ORDER GRANTING DEFENDANTS PASCAGOULA-GAUTIER SCHOOL DISTRICT AND MELISSA D’ANGELO’S MOTION [8] TO DISMISS FOR LACK OF JURISDICTION AND DISMISSING PLAINTIFF DENICE HAWS’S CLAIMS WITHOUT PREJUDICE

BEFORE THE COURT are the Motion [8] to Dismiss for Lack of Jurisdiction filed by Defendants Pascagoula-Gautier School District and Melissa D’Angelo on August 10, 2022, and the Order [10] to Show Cause entered by the Court on October 13, 2022. Plaintiff Denice Haws has not filed a Response to either the Motion [8] or the Court’s Order [10], and her time for doing so has passed. See L.U. Civ. R. 7(b)(4); Order [10] at 2. After consideration of the Motion, the record, and relevant legal authority, the Court finds that Defendants’ Motion [8] to Dismiss should be granted, and Plaintiff’s claims should be dismissed without prejudice. I. BACKGROUND Plaintiff Denice Haws (“Plaintiff” or “Ms. Haws”) filed a Complaint [1] alleging that Defendants Pascagoula-Gautier School District (the “District”) and Melissa D’Angelo (“Dr. D’Angelo”), the District’s Director of Student Services, abused their power by preventing Ms. Haws from enrolling her three minor grandsons, over whom she has domiciliary custody awarded by the Caddo Parish Juvenile Court in Shreveport, Louisiana (the “Juvenile Court”), in public school in the District for the 2022-23 school year. See Compl. [1] at 5; Ex. [1-2] at 2. Ms.

Haws relies upon a February 16, 2022, letter from the District, signed by Dr. D’Angelo, which stated that “District and state policies requires [sic] a certified copy of the order awarding guardianship or custody.” Ex. [1-2] at 2. The letter informed Ms. Haws that she would be “required to provide a certified copy of the order awarding custody prior to enrolling [her grandchildren] for the 2022-2023 school year.” Id. According to Ms. Haws, the Juvenile Court in Louisiana informed her that she would have to appear in person to secure such records, which

Ms. Haws states is a 14-hour drive and is not feasible. See Compl. [1] at 5-6. Ms. Haws filed a pro se Complaint [1] in this Court on March 31, 2022, advancing claims against the District and Dr. D’Angelo, in her individual capacity, for violations of the Equal Protection Clause of the Fourteenth Amendment under 42 U.S.C. § 1983; the Rehabilitation Act, 29 U.S.C. § 794; and the Americans with Disabilities Act, 42 U.S.C. § 12101, et seq. (“ADA”). See id. at 2-3. The Complaint

seeks damages and “equitable relief,” specifically that the Court grant Ms. Haws’s grandchildren’s enrollment based upon the legal documentation that she had already provided to the District, and that the Court prevent Defendants from denying enrollment of the children at schools in the District. Id. at 5. The District and Dr. D’Angelo have filed a Motion [8] to Dismiss pursuant to Federal Rule of Civil Procedure 12(b)(1), taking the position that there is no longer a live case or controversy, such that subject-matter jurisdiction no longer exists. See Mot. [8] at 1. According to Defendants, “[a]dditionally, the undisputed facts of this case establish there was never a live case or controversy as the purported

violations of Constitutional and federal statutory rights never occurred.” Id. The District and Dr. D’Angelo state that it is undisputed that the three minor children were enrolled in the school district by their mother, Hazel Lawrence (“Ms. Lawrence”), for both the 2020-21 and 2021-22 school years. See Mem. [9] at 1. All three “have substantive disabilities and are enrolled in special education programs.” Id. at 2. The two oldest children were withdrawn from school in September 2021, and in February 2022, Haws sought to re-enroll them without Ms. Lawrence’s

presence by using a copy of the Juvenile Court docket abstract. See id. The Juvenile Court docket abstract stated that on December 6, 2018, the court “plac[ed] the children in joint custody with the mother and maternal grandmother, with grandmother to be the domiciliary custodian” and the children could attend school “in their district which is appropriate as designated by the grandmother.” Ex. [1-2] at 9 (emphasis removed). However, the docket abstract

did not identify the maternal grandmother by name or otherwise specifically mention Ms. Haws. See id. Defendants argue that there was no way for the District to “discern from the abstract that Denice Haws is the unidentified maternal grandmother such that she holds legal custody of these children, and was able to establish bona fide residency within the school district.” Mem. [9] at 2. After this lawsuit was filed, the two oldest children were permitted to re- enroll for the remainder of the 2021-22 school year under an “in loco parentis regulation” under Mississippi law that allowed for enrollment on temporary basis. Id. However, Dr. D’Angelo advised Ms. Haws that the District “would require a

copy of the final decree from the Louisiana juvenile court to enroll the children for the 2022-23 school year, or the children’s mother, Hazel Lawrence, could enroll the children as she had done the previous two years.” Id. at 3. Then, while this case was pending, Ms. Haws and Ms. Lawrence enrolled the children “in the ordinary fashion without resort to the loco parentis provisions” for the 2022-23 school year, and Ms. Haws provided the District with a copy of the Juvenile Court’s final order awarding her joint legal custody of the minor children,

which Defendants state “has removed any impediment which would interfere with her ability to enroll the minor children in the future.” Id. at 4. For these reasons, the District and Dr. D’Angelo insist that the issues raised in the Complaint are now moot, and that the Court accordingly lacks subject-matter jurisdiction. See id. at 5-6. Defendants further argue that no constitutional violation ever occurred, nor were there any violations of the ADA or the Rehabilitation Act, and that Dr.

D’Angelo cannot be held individually liable under either statute. See id. at 6-9. On October 13, 2022, the Court required Ms. Haws to show cause why this case should not be dismissed. See Order [10] at 1-2. “In light of the procedural posture of this case and Defendants’ Motion [8] to Dismiss, the Court question[ed] whether there remains for resolution a live case or controversy under Article III of the Constitution.” Id. at 2. The Court cautioned Ms. Haws that if she did not file a written response to the Order [10] by October 31, 2022, or if she did not adequately show cause why this case should not be dismissed, the case may be dismissed without prejudice, without further notice to her. See id. at 2-3. Ms.

Haws has not responded to the Order [10] or filed anything else in this case since before Defendants filed their Motion [8] to Dismiss. II. DISCUSSION A. Relevant legal authority Defendants move to dismiss for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1). As the party asserting jurisdiction, Ms. Haws bears the burden of demonstrating that subject-matter jurisdiction exists.

See, e.g., In re S. Recycling, L.L.C.,

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Bluebook (online)
Haws v. Pascagoula-Gautier School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haws-v-pascagoula-gautier-school-district-mssd-2022.